The fund manager's VCC reporting calendar: ACRA, IRAS, MAS and investor deadlines in one checklist

A VCC reporting calendar is the list of recurring and event-driven deadlines a fund manager must track for the VCC, its sub-funds, its tax position and its investors. Most statutory dates run from the VCC's financial year end (FYE); a few run from fixed calendar dates (CRS, FATCA, Form C) or from the date a scheme was entered on MAS's list. This checklist puts the VCC's filings next to manager-level and investor-level items. Dates are from the official pages cited, as at October 2026; re-check them before relying on a date.

How to use this calendar

The calendar is organised by trigger, because a fund manager typically receives deadlines from several directions.

This page adds the fund-manager and investor layers to the VCC's statutory deadlines. A single owner for the consolidated calendar, usually in the manager's compliance or finance team, reduces the risk that a date falls between two service providers.

Event-driven and launch-year deadlines

• [ ] New sub-fund: register with ACRA within seven days of setting it up (ACRA post-registration guide, 15 June 2026). IRAS does not need to be notified of a new sub-fund (IRAS VCC e-Tax Guide, 22 April 2026).
• [ ] Change in officers' particulars: update ACRA within 14 days.
• [ ] New offer of a sub-fund as a restricted scheme: notify MAS through CISNet before the offer, with an information memorandum (MAS, Offers of Collective Investment Schemes, 5 October 2026).
• [ ] Change of investment strategy for a 13O/13OA fund: notify MAS; since 1 January 2025 an approved fund is no longer limited to the strategy originally approved (MAS FDD Cir 05/2026, para 5.1(c)).
• [ ] Winding up a sub-fund: obtain tax clearance from IRAS before the sub-fund is wound up (IRAS VCC e-Tax Guide).
• [ ] Material change to fees, gating, valuation policy or service providers: update investor disclosures, as MAS expects disclosures to be provided when material changes occur (SFA 04-G05 para 4.1.4).
• [ ] Holdings near the 30/50 limits (13O/13OA funds): check at each close or dealing day; a grace period of up to three months applies only to breaches beyond the investor's control.

Launch year

The first months after registration carry one-off deadlines:

The annual cycle, keyed to the financial year end

The statutory VCC dates are summarised below; vccfund.com.sg/compliance-calendar covers each ACRA and IRAS filing, penalties and extensions in detail.

ACRA charges S$200 for each application to extend the AGM or annual return deadline, and extensions should be sought before the deadline. A basis period in which the tax-scheme conditions are not met does not enjoy the exemption, which is why the manager's staffing and spending checks belong on the same calendar as the VCC's filings.

A worked example: FYE 31 December 2026

The following dates apply the rules above to a VCC with a 31 December 2026 year end. Weekends, public holidays and extensions change the practical deadline.

Restricted-scheme anniversary dates do not follow the FYE. Under SFA 13-N02, the first anniversary date is 12 months from the date the scheme was entered on MAS's list: a sub-fund entered on 15 March 2026 would have a first anniversary date of 15 March 2027, unless the responsible person moved it earlier by an amendment filed at least one month ahead. Aligning several sub-funds to one anniversary date can simplify the calendar.

Manager-level and MAS-facing items

The fund manager has its own obligations that run alongside the VCC's. SFA 04-G05 refers managers to the compliance toolkits on the MAS website for periodic returns, notifications and approvals rather than listing them in the guidelines. A manager's calendar typically includes:

• [ ] Periodic regulatory returns, as listed in the applicable MAS compliance toolkit.
• [ ] Annual licence fee: S$4,000 for an LFMC or a VCFM (MAS fund management licensing page, 29 August 2024).
• [ ] Notifications and approvals for changes in particulars, shareholders, directors and representatives.
• [ ] Review of outsourcing arrangements against MAS's Guidelines on Outsourcing (Financial Institutions other than Banks), effective 11 December 2024.
• [ ] Review of conflict-of-interest policies and allocation records, approved at an appropriate level of authority.
• [ ] The fund manager's own annual audit, separate from the VCC's audit.
• [ ] Headcount of qualifying investment professionals for each 13O/13U fund: portfolio managers, research analysts and traders who are Singapore tax residents earning more than S$3,500 a month, employed throughout each basis period (MAS FDD Cir 05/2026, para 3.4 and footnote 13).

The tax-scheme items sit at manager level because the award conditions are tested on the manager's staff and the fund's spending in Singapore, not on the VCC's filings. A manager running several VCCs or sub-funds should keep one register that maps each fund to its scheme, the headcount it relies on and the spending tier that applies.

Investor-facing reporting

Investor reporting is set by the fund documents rather than by statute (NAV production is covered in Valuation and NAV and onboarding records in Fundraising and KYC), so the list below is common market practice; check what each sub-fund's documents promise.

• [ ] NAV statements at each valuation point (open-ended) or at the interval the documents set (closed-end, often quarterly).
• [ ] Capital account statements, capital-call notices and distribution notices for closed-end sub-funds.
• [ ] Audited financial statements, delivered under ACRA's 14-day rule above.
• [ ] Updated disclosures when fees, liquidity terms, valuation policy or service providers change.
• [ ] Tax information investors need for their own filings; investors should obtain tax advice in their own jurisdiction.
• [ ] CRS and FATCA self-certification refresh when an investor's circumstances change.

What this page does not cover: penalties for each late filing and the detailed AML/CFT calendar (see vccfund.com.sg/compliance-calendar). To interpret this for a specific fund, you can register your enquiry through the contact options on this site.